Personal data protection policy in accordance with the requirements of Regulation No. 2016/679 of the European Parliament and of the Council of the European Union on the protection of natural persons with regard to the processing of personal data and on free movement of this data

1. General information

RUFFELL HOLDING LIMITED, established and operating under the laws of the Republic of Cyprus, hereinafter referred to as Ruffell, hereby notifies subjects of Personal Data located in the territory of the European Union or Personal Data received from the territory of the European Union, on the principles of processing personal data used by Ruffell in accordance with the requirements of Regulation No 2016/679 of the European Parliament and of the Council of the European Union "on the protection of natural persons with regard to the processing personal data and the free movement of such data" General Data Protection Regulation (hereinafter - GDPR).

Ruffell takes the necessary and sufficient organizational and technical measures to protect the personal data of the aforementioned persons against unauthorized or accidental access, destruction, modification, blocking, copying, distribution and other illegal actions by third parties.

2. When can we receive personal information

2.1. Ruffell Partners who have been granted the right to use the Ruffell owned Ruffell computer program (the "Program") may transfer their customer data (the "Customers") directly to Ruffell for the following purposes:

- create logins and passwords for the above clients to work with the program.

- analyzing the results of Clients' work with the Program in order to provide them with an individual approach to working with the Program

- organize direct communication between Ruffell and its Customers, including for advertising mailings, if the Customer has expressed the appropriate consent

- facilitate cooperation between the Client and the Partner and obtain good results from this cooperation.

2.2. Ruffell receives data from its Users which is automatically transmitted by the Ruffell website (hereinafter referred to as the Site) when using the software installed on the device.

All personal data is sent to Ruffell for strictly predetermined purposes.

3. What personal data we process

3.1. Ruffell Partners may provide us with the following personal information of its Clients:

• Name, age and contact details of Clients and their legal representatives

• Information about the Customer obtained during the provision of services to the Customer by the Partner, including data on the work in the Program

• Photo and/or video images

Ruffell Partners also provides us with data about its employees and third parties which they use to provide services under contracts entered into between Ruffell and the Partner;

3.2. Ruffell may receive the following data from Users of the Site:

• Name and contact details

• Information about activity on the Site, including IP addresses, cookie data, information about browsers (or other programs that access the Site and the Program), technical characteristics of equipment and software used by Users, dates and times of access to the Program . , addresses of requested pages and other similar information.

3. Conditions for the processing of personal data.

Ruffell recognizes the importance of processing personal data in accordance with the GDPR and announces the following:

3.1. The processing of Customers' personal data is only carried out if one of the following conditions is met:

- The customer has consented to the processing of his personal data for one or more specific purposes.

- The processing is necessary for Ruffell to comply with its legal obligations;

3.2. Since the agreement under which the Customer can access the Program is between the Customer and the Partner, we ask our Customers to take into account the following information:

- GDPR compliance is an integral part of any agreement between Ruffell and a Partner.

- Since the agreement under which the Customer can access the Program is between the Customer and the Partner, Ruffell undertakes to provide the Partner with the Customers' consent to the processing of personal data on a contractual basis.

- When receiving personal data about Customers from Partners, Ruffell proceeds from the fulfillment by the Partner of its obligations under the Contract.

- Ruffell will endeavor to assist Customers in dealing with Partners regarding the processing of personal data, if necessary.

4. Duration of data retention

The storage of personal data is not carried out